OMB Control Number: 0607–0810 American-Arab Anti-Discrimination Committee 1705 DeSales Street NW Suite 500 Washington DC 20036 April 27, 2018 Submission via email OIRA_Submission@ omb.eop.gov Lingjun Wang AD/CVD Operations, Office VII, Enforcement and Compliance International Trade Administration U.S. Department of Commerce 1401 Constitution Avenue NW Washington, DC 20230 RE: Comments to the Department of Commerce Proposed Collection to the Office of Management and Budget for 2019 American Community Survey The American-Arab Anti-Discrimination Committee strongly urges the U.S. Department of Commerce include the Middle Eastern-North African category for collection under the 2019 American Community Survey (ACS). The American-Arab Anti-Discrimination Committee (ADC) is the country’s largest grassroots Arab-American organization, serving the Arab American Community for over thirty-five years. ADC is committed to protecting civil rights, promoting mutual understanding, and preserving the Arab cultural heritage. ADC respectfully takes this opportunity to recommend the Department of Commerce consider and implement inclusion of the proposed Middle Eastern or North African (MENA) category in the 2019 American Community Survey (ACS). ACS requires an accurate count of the nation's population, covering every person in every household. ACS is integral to our democracy because the data collected affects our nation’s ability to ensure equal representation and equal access to important governmental and private sector resources for all Americans, across racial and ethnic lines. Census results are used to allocate seats and draw district lines for the United States House of Representatives, state legislatures, and local boards. ACS is used to target more than $600 billion1 annually in federal assistance to states, localities, and families; and to guide community decision-making affecting 1 Reamer, Andrew. “Counting for Dollars: The Role of the Decennial Census in the Geographic Distribution of Federal Funds.” GW Institute of Public Policy, 4 June 2017. Available at http://civilrightsdocs.info/pdf/census/CountingForDollars-Intro.pdf. 1 OMB Control Number: 0607–0810 schools, housing, health care services, business investment, and much more. These functions depend on a fair and accurate ACS. The Census, after its 2015 National Content Test, created a Race and Ethnicity Analysis Report that concluded, “it is optimal to use a dedicated ‘Middle Eastern or North African’ response category.”2 Unfortunately, certain population groups — Middle Eastern-North African (MENA), included in the “hard-to-count” populations—are at a higher risk of not being fully counted in the census.3 In past United States censuses, the MENA identity has been listed under the “white” racial category, if at all.i This reality of MENA populations not being fully counted is only exasperated by the Census Bureau current decision to not include collection under the MENA category.4 The identified MENA group have been historically underrepresented in the decennial census and ACS for decades, but need to be inclusively counted. What are the hard-to-count characteristics of the MENA community?5 Middle Eastern and North African Americans typically share certain characteristics that compound their risk of being undercounted, including: • Language Barriers: Areas with low rates of English proficiency have historically been undercounted, and more than one in five Arab Americans speaks English less than “very well.” • Poverty: Households in poverty are traditionally hard to count. While the national poverty rate in the U.S is 12.7 percent, more than one-fifth (23.3 percent) of the Arab American community faces poverty. • Age: Young people of color can be hard-to-count, especially young children and young adults. Compared to the general United States population, a higher proportion of Arab Americans are under 5 years old or aged 18-24. In addition, older individuals are more likely to be overcounted, 2 Census Bureau, 2015 National Content Test Race and Ethnicity Analysis Report xiii (Feb. 28, 2017), https://www2.census.gov/programs-surveys/decennial/2020/program-management/final-analysis-reports/2015nct- race-ethnicity-analysis.pdf. 3 “Final Report: National Advisory Committee on Racial, Ethnic, and Other Populations, Administrative Records, Internet, and Hard to Count Population Working Group.” U.S. Census Bureau, July 2016. Available at https://www2.census.gov/cac/nac/reports/2016-07-admin_internet-wg-report.pdf. 4 Census Bureau, https://www.census.gov/newsroom/press-releases/2017/cb17-tps15.html; Ali Harb, US Census fails to add MENA category: Arabs to remain 'white' in count, Jan. 27, 2018, http://www.middleeasteye.net/news/us- census-continue-count-arabs-white-1206288795. 5 “Table S0201: Selected Population Profile in the United States: 2016 American Community Survey 1-Year Estimates.” U.S. Census Bureau, Retrieved 13 December 2017. Available at https://factfinder.census.gov/bkmk/table/1.0/en/ACS/16_1YR/S0201//popgroup~504; Brownrigg et al. “Sociocultural Behaviors Correlated with Census Undercount.” 2003; Fernandez, Shatuck and Noon. Presentation at the Southern Demographic Association Conference, October 2016; Semega, Jessica, Kayla Fontenot, and Melissa Kollar. “Income and Poverty in the United States: 2016.” U.S. Census Bureau, 12 September 2017. Available at https://www.census.gov/library/publications/2017/demo/p60-259.html; “Final Report: National Advisory Committee on Racial, Ethnic, and Other Populations, Administrative Records, Internet, and Hard to Count Population Working Group.” U.S. Census Bureau, July 2016. Available at https://www2.census.gov/cac/nac/reports/2016-07- admin_internet-wg-report.pdf. 2 OMB Control Number: 0607–0810 but a smaller proportion of Arab Americans are seniors compared to the US population as a whole. • Gender: Men, especially men of color, have a higher undercount rate than women. More than half of the Arab American population (53.8 percent) is male, compared 49.2 percent nationally. • Housing Insecurity: Renters are harder to count because of their relative transitory status and the types of housing in which they live. Almost half of Arab Americans (49.6 percent) are renters compared to 37 percent of the general United States population. The Department of Commerce and OMB are considering major improvements in how they ask Americans about their race and ethnicity, with the goal of producing more accurate and reliable data in the 2019 ACS and beyond. Recently released Census Bureau related research underscores the fact that many Americans and U.S. persons do not identify completely or accurately with the current racial categories and have recommended using a combined question about race and ethnicity.6 This representation of identity in the ACS is shared by persons from the Middle East and North Africa. Middle Eastern and North African responses are currently classification as "White" under the OMB standards is inappropriate. The Middle Eastern category includes Arab Americans whom are not “White.” As demonstrated in the Census Bureau’s 2010 Alternative Questionnaire Experiment (AQE) focus groups, there is widespread agreement that the classification of Middle Eastern and North African people as “White” is inappropriate. Census Bureau officials have acknowledged that data accuracy is a problem because to obtain good data, they need to make sure people can match themselves to the choices they are offered. Arab Americans and persons of Middle Eastern and North African origin are not provided an accurate choice for their identity, which inevitability leads to inaccurate and underreported count. Although the full breadth of the MENA community is as yet unknown, there are estimated to be at least 3.7 million Americans of Arab descent in the United States.7 Arab Americans comprise approximately 77 percent of the projected MENA population.8 Upon 6 See Pew Research, Seeking Better Data on Hispanics, Census Bureau May Change How It Asks About Race, http://www.pewresearch.org/fact-tank/2017/04/20/seeking-better-data-on-hispanics-census-bureau-may-change- how-it-asks-about-race/ 7 The Arab American Institute estimates that there are 3.7 million Arab Americans in the U.S., including Iranian and Israeli Americans. Since the American Community Survey does not include these two groups in its “Arab” categorization, its estimate of about 2.8 million Arab Americans covers only 77 percent of the full classification. Authors calculations based on Ibid.; “Demographics.” Arab American Institute, Retrieved 2017.; 2016 American Community Survey 1-Year Estimates. 8 Goldvale, Casey and Indivar Dutta-Gupta. “Counting Everyone in the Digital Age.” The Leadership Conference Education Fund and the Georgetown Center on Poverty and Inequality, 2017. Available at http://www.georgetownpoverty.org/wp-content/uploads/2017/10/LCEF_2020_Census_Poll_Report-Final-002.pdf; 3 OMB Control Number: 0607–0810 receiving extensive input from the MENA community and observing positive reception and higher data quality when testing the MENA category in 2015, the Census Bureau formally recommended that the MENA category be added to the 2020 Census.9 The change in the Census Bureau position in January 2018 contravenes the MENA category testing.10 The Census Bureau seems to have ignored all its prior research and testing on a MENA classification. NCT research has explored ways to collect and tabulate data for respondents of Middle Eastern or North African (MENA) heritage.11 During the 1990s, as